Rennies Coaches Privacy Policy

Rennies Coaches (“Rennies”, “we”, “us”, “our”) is a trading name of Fife Scottish Omnibuses Ltd, trading as Stagecoach East Scotland, Stagecoach in Fife, Stagecoach in Perth, Stagecoach Strathtay and Rennies Coaches. The ultimate parent company is Stagecoach Group Plc, a company registered in Scotland (Registered No. SC 100764) whose registered office is at 10 Dunkeld Road, Perth, PH1 5TW Scotland.

Rennies values the personal information you provide to us and wouldn’t want to use your personal data in a way that you wouldn’t expect. This Privacy Policy explains how we protect your privacy and how you control the use of your personal information.

Having read this information, if you want to change the way in which we use your data or if you have a question about how your personal information is used please contact the Data Controller for customer information: Stagecoach Services Limited using the methods below:

Email: ukbus.datacontroller@stagecoachbus.com
Phone: 0161 880 5000
Postal address: One Stockport Exchange, 20 Railway Road, Stockport, SK1 3SW

Our ICO Registration Number is: Z6391021 and can be viewed here

1. Where and how we collect your personal information

We collect personal information about you in several ways:

• When you fill in a form on our websites, Stagecoach Bus app or WI-FI portal
• When you contact us via phone, email, social media or another route
• When you register with us and fill in a form on our website or mobile app, either directly or via a social media account
• When you subscribe to our services
• When you purchase tickets
• When you make a booking with us
• When you opt-in to receive special offers and promotions, travel tips and latest news by email, post and other electronic means
• When you enter a competition, prize draw or promotion
• When you complete a survey distributed by us or on our behalf
• When you browse our website, use the Stagecoach Bus App or use our coach WI-FI
• When you open or click on any marketing emails we send you

We also collect your personal information from other organisations and sources, for example when you contact us through a social media company such as Facebook, Twitter, LinkedIn or Instagram. Before providing information to us via these channels you should check these companies’ privacy policies and settings to understand how they use your personal information.

2. What personal information do we collect and hold about you?

When you fill in a form, make a booking or purchase tickets we only require you to supply the information that we need to provide the service you have requested. We will normally ask you to provide us with:

• Your name
• Your contact details
• Details of your bank, credit card or alternative payment provider
• Identification details including but not limited to Student ID or concessionary pass
• Your location, ticket and travel information
• Information when reporting a problem, submitting queries or comments
• How you would like us to contact you We don’t collect date of birth information but we recognise that young people use our services and are legally able to provide consent after the age of 13 years. If you are using our local bus services and are aged between 13 and 16 years of age we recommend that you read our terms and conditions (https://www.stagecoachbus.com/online-sales-terms-and-conditions). When you buy a ticket, book a hire or travel with us, we will let you know if you need to provide further information and which information is optional. When you visit our websites, Stagecoach Bus app or register to use our coach WI-FI services, we may collect the following information automatically:
• Technical information, including the IP address used to connect your computer to the Internet, unique identifiers assigned to your device, your login information, the browser you’re using, time zone setting, browser plug in types and versions, the operating system, device type and platform you are using;
• Location data and WI-FI usage
• Information about your web or app visit that will help us to improve our service. This can include date and time, which products you looked at or searched for, how long you spent on certain pages, resources you access and how you moved around the page, how you clicked to, through and from our websites or Stagecoach Bus app and any phone number used to contact us. In our communications with you by email or other electronic means, we automatically collect data relating to:
• How you interact with our communications, such as which emails you opened or clicked a link within, and how long the email was opened for
• Where you are when you interact with our messages
• What type of device, model and operating system you’re using.

We also collect information about your visits to our website using cookies. This helps us build a better picture of whether our marketing is effective When you complete a survey, we may collect additional personal information for customer profiling and monitoring purposes, including (but not limited to): age, gender, employment status, postcode and email address. Whilst we mainly use the personal information that you provide to us, we may sometimes use other public sources of information about our customers and enquirers where you have given your permission for your data to be shared. We do this to help us understand more about our customers, to ensure that our public messages are relevant and to make sure that the marketing information we send you, with your consent, is also relevant. We take great care in sourcing this information but if you prefer us not to use your data in this way then please let us know by contacting ukbus.datacontroller@stagecoachbus.com

3. CCTV

We employ CCTV on our buses in order to:

• Prevent, deter and detect crime
• Apprehend and prosecute offenders, and provide evidence to take action in the courts
• Help provide a safer environment for our staff
• Protect public safety
• Monitor operational and safety-related incidents
• Assist with the verification of claims. You have the right to make a Subject Access Request for CCTV images of yourself and to ask for a copy of them. Please direct any such request to ukbus.datacontroller@stagecoachbus.com.

To protect the rights of other individuals whose images may also be captured by the same images, we reserve the right to redact images. We reserve the right to withhold information where permissible by the applicable data protection legislation, and we will only retain CCTV images for a reasonable period or as long as is required by law. In certain circumstances, we may need to disclose CCTV images for legal reasons. When this is done, there is a requirement for an organisation that has received the images to adhere to the relevant data protection legislation.

4. Our legal basis for using your personal information

Under UK data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are four ways we may have a valid basis for using your personal information:

1. Contract—Most of the information we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you may provide a billing address when you book via our website; we may need to contact you to notify you about changes to your booking.
2. Consent—When you register and open an online account on stagecoachbus.com us you will be invited to give us your consent to use your personal information as described in ‘How we use your personal information for marketing’. By opting in you are giving us your permission to process your data using consent as our legal basis. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time.
3. Legitimate Interests—We have a legitimate interest in using your personal information e.g. to ensure that the content on our websites and Stagecoach Bus app is presented to you and your device as effectively as possible. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information. We also have a legitimate interest in exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Legal Obligation—Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.

A full description of the different types of personal information we process, the purpose of the processing and the legal basis for the processing is shown below:

5. Our legitimate interests and your right to object

Legitimate Interests means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].

For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so, please let us know by contacting ukbus.datacontroller@stagecoachbus.com Please bear in mind that if you object, this may affect our ability to carry out the tasks for your benefit.

6. How we use your personal information

We use the personal information you provide to:

• Provide you with the service or information you’ve requested
• Handle the administration of your account, payment, enquiry, issue your tickets or confirm bookings
• Alert you about updates to your journey, timetable, tickets or booking
• Provide post-sales support and deal with any complaints, refunds or other ticketing or travel issues or queries
• Contact you to invite you to participate in research
• Personalise your experience of our websites and Stagecoach Bus app by using your purchases and browsing activity to make recommendations that we think may be of interest to you
• Improve our websites, Stagecoach Bus app and the range of services and products we provide
• Analyse and optimise our marketing activities
• Evaluate and improve our existing products and services, or develop new ones
• Contact you with your consent to tell you about our special offers and promotions, travel tips and latest news

7. How we use your personal information for marketing

We only use your personal information for marketing where you have given us permission to do so or you have provided permission to other organisations to allow us to market to you.

Where you’ve given us permission to do so, we use some of your personal information for marketing. For example, we may use information like name, address, location and past bookings to ensure we make our marketing relevant, accurate, and measure its effectiveness.

By using the information you provide we are able to contact you with specific marketing messages about special offers and promotions, travel tips and latest news and, depending on the permission you have given us or another organisation this may be by post, email, telephone, SMS social media or other electronic means.

If you have given us your consent to use your personal information for marketing, you have the right to withdraw your consent at any time by contacting our Data Controller on 0161 880 5000, clicking the “unsubscribe” link in our marketing. You can also contact us via the form on Rennies.co.uk at anytime to request an update to your marketing opt-in.

8. Sharing your personal information

Rennies Coaches may share your information within companies within the Stagecoach Group. We do not share or sell your personal information to any other company for marketing purposes.

Third-party companies will be required to use your personal information in accordance with the Data Protection legislation currently in force. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.

Where we use trusted suppliers to help us deliver our service to you, we allow the supplier concerned limited access to the personal data they need to provide their service. A list of just some of the service suppliers are listed below:

• Mailing houses to send you offers
• A cloud hosting company, which we use to run our websites, Stagecoach Bus app, retail, timetable and database services
• Website hosting companies which we use to administer our website content, including personalised timetables
• Third party payment providers including but not limited to World Pay and Braintree
• An email service provider to send you emails about the tickets you buy and travel information you have requested
• Our on-coach WI-FI supplier
• Third parties which we use to analyse traffic and other pseudonymised data on our websites and Stagecoach Bus app and use of our services
• Market research and analysis organisations working on our behalf
• Organisations that support our ticketing activities
• Agencies that handles our customer service enquiries, complaints and refunds
• Fraud checking and prevention organisations
We also use trusted suppliers to help us with marketing:
• An email service provider to send our emails and make sure you only receive what you have asked for
• A mailing house to send out marketing by post
• A telemarketing agency to contact you by phone or SMS
• Online media owners who help us target, deliver and track our marketing campaigns using cookies.

All personal information sent to our trusted suppliers is transferred securely. In all cases we require these companies to comply strictly with our instructions and they are not allowed to use your information for their own business purposes. We also require these companies to have sufficient organisational and technical measures in place to ensure the security of your personal information.

We may use suppliers who operate outside of the country of which you are a resident, for example in the United States. These countries may not offer the same legal protection of your personal information as the UK. If we use one of these organisations, we take appropriate steps to ensure that they provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing of your personal information at our approved locations outside the EEA. If you would like to know more about the ways in which we safeguard your personal information, please get in touch using the contact details in this policy.

Under some circumstances we may be required to disclose or share your information without your consent, for example if we are required by the police, the courts or for other legal reasons.

9. Your rights regarding our use of your personal information

You provide us with details of what we ‘can do’ with your data and have the right to manage your choices as detailed in How we use your personal information for marketing above. You have the following rights:

• To know that your data is being processed
• To access your personal data by making a Subject Access Request (SAR)
• To have your information corrected if inaccurate
• To data portability if applicable
• To request that your data be erased, to restrict processing, to object to processing and;
• To be made aware of your rights relating to automated decision making and profiling

10. Automated Decision Making

An automated fraud assessment may take place to make a decision whether to accept or decline your purchase or booking. You have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting us using the contact details provided

11. Accessing your Data by Subject Access Request (SAR)

You have the right to request a copy of the information that we hold about you, this is known as a Subject Access Request (SAR). We will provide this to you free of charge once we have confirmed your identity within 30 days of receipt of your request.

If you would like a copy of some or all of your personal information, please email or write to us using the contact details in this policy. Unless you specify otherwise we will provide your information electronically.

If we do hold information about you we will:

• Give you a description of it
• Tell you why we are holding it
• Tell you who it could be shared with
• Tell you how long we will keep the information
• If the information was not provided by you, we will give you any available information such as the source of the data
• Tell you if the information has been used for automated decision making and explain the logic involved in the decision making process
• Tell you if the information is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal information
• Let you have a concise and clear copy of the information

12. How we keep your personal information up to date

We have a legal obligation to keep the personal information we collect accurate and up to date. You have the right to ask us to correct any inaccuracies in the personal information we hold about you and to restrict the use of your information until it has been corrected.
The simplest way to keep your data accurate is to log in into your Oxford Tube Mobile Ticket App account to update your information or change marketing preferences.
We also keep your information accurate by:

• Giving you the opportunity at anytime to contact us to correct or change your information (https://www.rennies.co.uk/contact-us )
• Asking you to confirm certain details when you contact us

We have specific rectification, restriction objection and erasure policies in place to make sure we respond effectively to your request to correct data and to respond to erasure requests.

13. How we keep your personal information safe

We use administrative, electronic and physical security measures to ensure the information we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.

By using our website and/or services, you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.

14. How long we keep your personal information

Of the data we process outside of any contract we retain the data for no longer than is necessary. Where there is a legal requirement to retain data for longer than Rennies Coaches requires, we will do so. Where reasonably practicable data is minimised so not to be identifiable to the data subject unless required by law or is subject to a Subject Access Request.

We keep your personal information where we have:

• A legal or regulatory requirement that requires us to hold data for a specific time
• A legal basis to retain data including data opt-ins, revised opt-ins and renewed consents

If you would like more information about the length of time we retain your data please contact our Data Controller.

15. What to do if you have a complaint about our use of your personal information

If you have a complaint about the information we hold or how we use that information, please contact our Data Protection Officer (dataprotectionofficer@stagecoachgroup.com) who will deal with your request promptly. If you are not satisfied with the way your complaint was handled, you can refer your complaint to UK Information Commissioner’s Office. https://ico.org.uk/concerns/

16. Links to other websites

We link our website directly to other sites. This privacy notice does not cover the links within our site linking to other websites and organisations. We encourage you to read the privacy statements on the other websites you visit.

17. Changes to this privacy notice

This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation using the contact details at the beginning of this privacy policy. We keep our privacy notice under regular review. This privacy notice was last updated on 23.05.18